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Adopt in an existing estateCompliance starter kits

Fintech - PCI DSS v4.0

For a payment platform, neobank, buy-now-pay-later provider or other fintech preparing for a PCI DSS v4.0 assessment. The kit deploys from the pcidss.compliance.tf registry host and builds in the decisions that are hardest to change later: cardholder data environment (CDE) segmentation, RDS encryption at creation and a private data layer. When you finish, the stack is applied and every PCI DSS v4.0 control its modules enforce has passed terraform plan.

Repository: compliancetf/starter-kit-fintech-pcidss · About 130 resources

Before you start

  • The shared prerequisites on Compliance starter kits: an account whose plan includes PCI DSS v4.0, Terraform at a version every module accepts, AWS credentials, a Route 53 hosted zone, the replication role and destination bucket, and account-level CloudTrail. PCI DSS Req. 10.2 expects the CloudTrail trail alongside the resource logs this kit configures.
  • Leave RDS encryption on. storage_encrypted = true has to be set when the database is created; AWS cannot encrypt an existing instance without a snapshot and restore to a new one. The kit enforces encryption by default.
  • Decide how you will handle MFA delete before the first apply. The kit requests MFA delete on the data and logs buckets, and s3_bucket_mfa_delete_enabled enforces it, but AWS accepts that change only from the root user with an MFA code, and does not allow lifecycle rules on a bucket with MFA delete, while the logs bucket ships a 365-day lifecycle. The usual path: turn the control off for the rollout, keep the lifecycle, and if your QSA requires MFA delete, have the root user enable it on a bucket without lifecycle rules. Do not run the whole apply as root. Turning the control off means switching the s3_bucket_data and s3_bucket_logs sources in main.tf to the HTTPS form with ?disable=s3_bucket_mfa_delete_enabled (see Turn off a control) and adding a .netrc entry for pcidss.compliance.tf, because terraform login does not cover HTTPS sources; see Registry endpoints.

Deploy

git clone https://github.com/compliancetf/starter-kit-fintech-pcidss.git
cd starter-kit-fintech-pcidss

cp terraform.tfvars.example terraform.tfvars
# Set project_name, domain_name, route53_zone_id, availability_zones,
# s3_replication_role_arn and s3_replication_destination_bucket_arn

terraform login pcidss.compliance.tf

terraform init
terraform plan
terraform apply

If a value in terraform.tfvars violates a PCI DSS v4.0 control, terraform plan fails. The error names the control and the module. Fix the value and plan again.

What it deploys

PCI DSS fintech infrastructure architecture

Two layers. The public edge (CloudFront, WAF and ALB) routes requests and enforces protocols. The CDE layer (EKS, Lambda, EC2, Aurora PostgreSQL, DynamoDB and ElastiCache) is private, with no public route to any data store.

ModuleVersionPurposePCI DSS v4.0 requirements
vpc~> 6.0CDE network isolation, flow logsReq. 1.3 (restrict CDE access), Req. 10.2 (audit logs)
alb~> 10.0HTTPS load balancing, access logsReq. 4.2.1 (TLS 1.2+), Req. 6.4.1 (WAF association)
cloudfront~> 6.0CDN edge with TLS and WAFReq. 4.2.1 (TLS at edge), Req. 6.4.1 (WAF)
waf~> 1.0Regional WAF (ALB), OWASP Top 10Req. 6.4.1 (web application protection)
waf_global~> 1.0Global WAF (CloudFront, us-east-1)Req. 6.4.1 (web application protection at edge)
acm~> 6.0Regional TLS certificateReq. 4.2.1 (strong cryptography in transit)
acm_us_east_1~> 6.0Global TLS certificate for CloudFrontReq. 4.2.1 (strong cryptography in transit)
kms~> 4.0Customer-managed key wired to EKS, Lambda, and OpenSearchReq. 3.5.1 (PAN rendered unreadable)
eks~> 21.0Kubernetes cluster, private endpoint, encrypted secretsReq. 2.2 (secure configuration), Req. 10.2 (audit logs)
lambda~> 8.0VPC-attached functions, KMS environment encryptionReq. 1.3 (restrict CDE access), Req. 3.5.1 (encryption)
ec2_instance~> 6.0Private worker nodes, IMDSv2, IAM instance profileReq. 2.2 (no public IP, IMDSv2 enforced)
rds_aurora~> 10.0Aurora PostgreSQL, encrypted at creation, Multi-AZ, IAM authReq. 3.5.1 (encryption at rest), Req. 10.2 (audit logs)
dynamodb~> 5.0Key-value store, KMS encryption, PITRReq. 3.5.1 (encryption at rest)
elasticache~> 1.0Redis, encrypted at rest and in transitReq. 4.2.1 (TLS in transit)
s3_bucket_data~> 5.0CDE data storage, KMS, versioning, cross-region replicationReq. 3.5.1 (encryption at rest), Req. 3.5 (no public access)
s3_bucket_logs~> 5.0Audit log storage, versioning (MFA delete requested, see Before you start), cross-region replication, 365-day lifecycleReq. 10.3 (log protection), Req. 10.5.1 (log retention)
sqs~> 5.0Message queue with dead-letter queueReq. 3.5.1 (SSE encryption)
opensearch~> 2.0VPC-only search, KMS, HTTPS, fine-grained access, audit logsReq. 10.2 (audit logs), Req. 10.3 (log protection)
cloudwatch~> 5.0Application log group, 365-day retentionReq. 10.2 (audit logs), Req. 10.5.1 (log retention)

CloudFront accepts certificates only from us-east-1, wherever your other resources are, so the kit provisions two ACM certificates: a regional one for the ALB and a global one for CloudFront, through a provider alias. Both validate against the same Route 53 zone.

Control coverage

PCI DSS v4.0 requirementDescriptionModulesWhat the kit configures
Req. 1.3Network access to and from the cardholder data environment is restrictedVPC, Lambda, RDS Aurora, ElastiCachePrivate and database subnets, no public routes to any CDE data store, VPC-attached functions
Req. 2.2System components are configured and managed securelyEC2, EKSIMDSv2 required, no public IPs, IAM instance profiles, private cluster endpoint
Req. 3.5Primary account number (PAN) is secured wherever it is storedS3, RDS AuroraPublic access blocked, encryption enforced
Req. 3.5.1Primary account numbers (PAN) are secured with strong cryptography wherever storedS3, RDS Aurora, DynamoDB, Lambda, KMSEncryption at rest on every CDE data store: the kit's customer-managed key on EKS, Lambda and OpenSearch, the service's AWS encryption elsewhere unless you pass key ARNs
Req. 4.2.1Strong cryptography is used to safeguard PAN during transmissionALB, CloudFront, ElastiCacheTLS 1.2+ enforced on all connections
Req. 6.4.1Public-facing web applications are protected against attacks on an ongoing basisALB, CloudFrontWAF with OWASP Top 10, known bad inputs, IP reputation
Req. 10.2Audit logs are implemented to support detection of anomalies and suspicious activity and the forensic analysis of eventsAll modulesVPC flow logs, ALB access logs, EKS audit logs, CloudWatch log groups
Req. 10.3Audit logs are protected from destruction and unauthorized modificationsS3 (logs), OpenSearchS3 versioning, MFA delete once the root user enables it, cross-region replication once the rule covers KMS objects (see Before you start), OpenSearch index retention
Req. 10.5.1Audit log history is retained for at least 12 months, with the most recent 3 months immediately availableS3 (logs), CloudWatch365-day retention on the log group and the logs bucket; the 90-day Glacier transition keeps the most recent three months in standard storage (immediately retrievable) while older logs stay retained through 365 days — confirm these thresholds with your QSA, since 365/90 days approximate the calendar months the requirement names

Settings a module enforces as a control fail the plan if you change them. The rest are kit defaults you can change. The PCI DSS v4.0 framework page lists the controls modules enforce. It also lists the mapped-only controls your team handles.

What you own

The kit configures the infrastructure settings above. These stay with you:

  • Tokenization and PAN handling in application code (compliance.tf does not tokenize)
  • Key rotation procedures and key administrator access policies
  • User access reviews and role assignments
  • Change management approvals and evidence collection
  • Annual penetration testing (PCI DSS Req. 11.4 requires both internal and external testing at least once per 12 months)
  • QSA engagement and Report on Compliance (ROC) preparation
  • Cardholder data discovery and formal CDE scope documentation

CDE scoping

A smaller cardholder data environment means fewer QSA hours and a cheaper assessment.

In CDE scope: VPC private subnets, EKS, Lambda, EC2, RDS Aurora, DynamoDB, ElastiCache, S3 data bucket, OpenSearch

Typically out of CDE scope: SQS (application queuing for non-PAN data) and the CloudWatch log group (aggregated logs only). CloudFront is out of scope only when it serves static assets — a distribution that transmits cardholder data is in scope (covered under AWS's PCI attestation for the AWS-managed portion). Confirm scoping decisions with your QSA.

The modules in CDE scope have KMS encryption at rest, checked at terraform plan (the kit's customer-managed key is wired to EKS, Lambda, and OpenSearch; other services use their respective AWS encryption defaults unless you pass key ARNs). The out-of-scope modules use standard server-side encryption.

QSA evidence

When your QSA asks about infrastructure controls, this is where the evidence is:

QSA questionWhere to find the evidence
Is cardholder data encrypted at rest?Terraform state: aws_kms_key, aws_rds_cluster, aws_s3_bucket_server_side_encryption_configuration
Is TLS 1.2+ enforced on all endpoints?ALB listener policy: ELBSecurityPolicy-TLS13-1-2-2021-06; CloudFront security policy: TLSv1.2_2021
Are databases in private subnets with no public endpoint?VPC subnets: aws_subnet with map_public_ip_on_launch = false; RDS publicly_accessible = false
Is WAF protecting web-facing applications?aws_wafv2_web_acl association with ALB and CloudFront distribution
Are audit logs retained and protected?S3 logs bucket versioning and replication configuration, plus replication metrics showing encrypted objects arrive; OpenSearch index retention settings
Is IMDSv2 enforced on EC2 instances?aws_instance with metadata_options.http_tokens = "required"

Customize

Turn off a control

Use the HTTPS source with ?disable=:

module "s3_bucket_data" {
  source = "https://pcidss.compliance.tf/terraform-aws-modules/s3-bucket/aws?version=5.0.0&disable=s3_bucket_event_notifications_enabled"
  # ...
}

That example turns off the S3 event notification control, which has nothing to do unless something in your account consumes those events. Do not turn off an encryption, public-access or logging control on a module in CDE scope: your QSA will ask why it is absent, and the answer has to be a scoping decision, not a disabled check. Only a control the module enforces can be turned off; Turn controls on and off explains the limits and how to record the reason.

Adjust sizes or remove a module

Instance sizes and counts are variables; override them in terraform.tfvars, with the names in the repository's variables.tf. To drop a module the application does not use, delete its block from main.tf and its outputs from outputs.tf, then check that no other module references it.

Cost

ComponentDevProd
VPC + NAT Gateway~$35~$100
ALB~$25~$25+
CloudFront~$1~$5+
EKS control plane~$75~$75
EKS nodes (t3.medium)~$60~$120+
Aurora PostgreSQL (db.r6g.large)~$200~$400
ElastiCache (cache.t4g.micro)~$10~$20
OpenSearch (t3.small.search)~$20~$60
S3 + Lambda + SQS + EC2~$30~$60+
Total of the rows~$456~$865+

The total is the sum of the rows above. The table has no rows for the two WAF web ACLs, DynamoDB, KMS or CloudWatch Logs, so add those. Usage charges come on top: data transfer, NAT gateway data processing, log ingestion, and KMS and WAF requests. Actual costs depend on usage, data transfer and region. Infracost estimates them from your own terraform plan.

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